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Case 6:12-cv-01257-RBD-KRS Document 2 Filed 08/15/12 of 16 PagelD 18

1\\OIN THE CIRCUIT COURT OF THE EIGHTEENTH JUDICIAL CIRCUIT

IN AND FOR BREVARD COUNTY, FLORIDA

RICHARD AND JUDITH FICKES 05-20- eig .-(11S1/07 -XXXX-XX3666 Mary Lou Lane

Melbourne, FL 32934on behalf of themselves andall others similarly situated

Civil Action Case No 1.. 1:...:Plaintiffs,

co rn

Vs

VOLKSWAGEN OF AMERICA, INC CLASS REPRESENTATION Lo

2200 Ferdinand Porsche Drive

Herndon, VA 20171

Defendant

COMPLMNT

Plaintiffs, Richard and Judith Fickes ('the Fickeses" or “PlaintifIr), on behalfof themselves

and all others similarly situated, by their undersigned counsel, allege, against Defendant Volkswagen

of America. Inc (-Volkswagen- or "Defendant-), the following upon personal knowledge as to their

Own acts, and upon information and belief, based on the investigation conducted by their counsel, as

to all other allegations.

SUMMARY OF THE ACTION

1 Plaintiffs bring this class action complaint on behalf of themselves and all other

persons in the State of Florida who purchased and/or leased a Volkswagen vehicle for personal,

family or household use, which vehicle had or currently has a defective fuse box/alternator cable

Case ti 05-2012-CA.045407-XXXX-XX

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Clcctrical system that melted or burned, or is at risk of melting or burning, thereby causing or

threatening to cause the vehicle to lose power while underway in traffic or to catch fire A

photograph of a typical damaged fuse box/alternator cable assembly can be seen below

2

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Pictures available at http //newheetle org/forums/questions-issues-concerns-problems-new-

beetle/28982-battery-fuse-box-melting-04-new-beetle html, accessed on September 20, 2011

The vehicles affected include (a) the 2003-2005 New Beetle Convertible, (b) and (1))

the 1999-2005 New Beetle (the "Vehicles")

3 The failure of the fuse box/alternator cable assemblies is not a result of normal wear

and tear or a reasonably expected failure rate for new parts, but is a basic design defect that existed at

the time of manufacture of each vehicle and is believed to be related to the current carrying capacity

of one or more components of the assemblies

4 By complaints of its customers, both directly and through its dealers, Volkswagen was

on notice that the fuse box/alternator cable assemblies were defective and not fit for their intended

purpose of properly and effectively distributing electrical charge to the battery and power to other

systems Volkswagen actively concealed and/or failed to notify the public of the existence and nature

of said defects or of the possible safety issues presented by the defects Volkswagen has not recalled

the Vehicles to repair the defects, it has not offered to repair the defects to its customers free of

charge, and it has not offered to reimburse owners, present or past, who incurred costs relating to

system repairs

5 Plaintiffs allege that Volkswagen is responsible and liable for the costs of inspecting

and replacing the defective fuse box/alternator cable assemblies and reasonable attorneysfees

PARTIES

6 Plaintiffs Richard and Judith Fickes bring this action in their individual capacities and

On behalf of all others similarly situated On May 7, 2008, Plaintiffs purchased a 2004 New Beetle

3


convertible from Gator Chrysler, Inc, of Melbourne, Florida At the time of purchase, Plaintiffs

were residents of Brevard County, Florida, and the vehicle was registered and insured in the State of

Florida Plaintiffs intended to use, and continue to use, the vehicle in Florida They are currently

residents of the State of Florida where said vehicle is now registered

7 Defendant Volkswagen is a domestic corporation, with its principal place ofbusiness

and national headquarters located in Herndon, Virginia Defendant designs, manufacturers and sells

automobiles under the Volkswagen brand name throughout the United States, including in the State

of Florida Defendant does business in Florida Defendant's Volkswagen models are advertised,

distributed and sold at multiple places ofbusiness in Florida through Defendant's dealers, including

prestige Volkswagen of Melbourne, Florida, wherc Plaintiffs have their vehicle serviced These

locations were and are maintained by Defendant's dealers for the sale or Defendant's vehicles,

including the 2004 New Beetle, and Defendant has sold the years and models in question in the

Florida during the Class Period and presently

JURISDICTION AND VENUE

8 Jurisdiction and venue for purposes of this action are conferred upon this Court

Pursuant to Fla Stat 501.201 The total damages to the class are alleged to be less than

$5,000,000 Plaintiffs will neither seek nor accept damages for the class in excess of $5,000 000 In

addition, Plaintiffs' damages are less than $75.000, and Plaintiffs will neither seek nor accept

damages in excess of $75,000

FACTUAL BACKGROUND AND SUBSTANTIVE ALLEGATIONS

9 Plaintiffs purchased their 2004 New Beetle on May 7, 2008 At the time ofpurchase,

Volkswagen's 4-year warranty on parts and service had expired This warranty as applied to the

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8cfects herc is unconscionable and serves mainly to protect the Defendant from liability for the cost

of replacement The fuse box/alternator cable assembly was defective, and was known by Defendant

to be defective, from time of manufacture and belbre the vehicle's original sale on April 10, 2004,

and was therefore defective before the warranty began to run Neither the Plaintiffs nor the prior

owners knew, or could have known, ofthis defect at the time ofPlaintiffs' purchase or at the time an

original purchaser purchased the Vehicle

10 At the time oforiginal sale in 2004, Volkswagen, through its dealerships, employees,

agents and servants represented to the public that the Vehicles containing the defectively designed

assembly were in good condition and fit for their intended purpose In this manner, Volkswagen was

able to place the Vehicles in commerce and profit from their sales

11 From the date of purchase to the present, Plaintiffs serviced the vehicle timely and

properly

12. In June 2011, Plaintiff Richard Fickes took the vehicle to Prestige Volkswagen to

have a problem with the rear window repaired While the vehicle was at Prestige, the mechanic

recommended checking the fuse box/alternator cable assembly because of known problems with the

assembly components overheating and melting the fuse box Upon inspection, the mechanic

determined that the fuse box had been seriously burned and needed to be replaced The notation on

Plaintiffs' invoice for the replacement costs stated

POSITIVE BATTERY CABLE AND FUSE PANEL BURNTFOUND AUX FUSE PANEL BURNT AND ALTERNATOR CAI3LE DAMAGEDREPLACED AUX FUSF PANEL AND REPLACED ALTERNATOR CABLE2 OHRS TOTAL [sic]CONTACTED VOLKSWAGEN OF AMERICA FOR ASSISTANCE REQUEST

A copy of the Prestige invoice is attached as Exhibit A hereto

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13 Plaintiffs paid the entire amount of $438 58 billed for labor and parts related to the

repair of the fuse box and cables Volkswagen paid nothing

14 Volkswagen, through its dealerships, agents, servants and employees, were put on

actual and/or constructive notice of the defective fuse box/alternator cable assembly since at least

quo 1, and most likely earlier For example, in a safety review on the website "car-and-safety corn,

on May 16, 2001, a consumer reported a problem with,

ELECTRICAL SYSTEM.FUSES AND CIRCUIT BREAKERSCOOLING FAN FUSE HOLDER ASSEMBLY SIT [sic] ON TOP OFTHE BATTERY IN THE ENGINE COMPARTMENT THIS HOLDERHAS A HISTORY OF FAILURE (ACCORDING TO THEMECHANIC AT THE DEALERSHIP) THE FUSE ARCHEDAND MELTED THE ASSEMBLY THIS IS TROUBLESOME GIVENTHE CLOSE PROXIMITY TO THE EXPLOSIVE GASES WHICH AREGENERATED BY THE BAITER Y [emphasis supplied]

VOLKSWAGEN NEW BEETLE 1999 Safety Review #745454 (May 16, 2001), http ficar-and-

safety com/volkswagen-new-beetle-safety/volkswagen-new-beetle-1999 htm, accessed on September

2i), 2011

Similarly, another consumer noted on October 11, 2010, that he had gone through 2 fuse

bbxes and was looking to replace the alternator wire See

hitp llvolkswagenforum com/forum/volkswagen-heetle-2Wmelted-fuse-box-24117/, accessed on

September 20, 2011 Many other consumers have experienced the same problems, and numerous

pictures of the failure have been posted to the web,

hup //forums fourtitude com/showthread phi:04562591, accessed on September 20, 2011

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15 Upon information and belief, there have been many reports of the Vehicles being

consumed by fire from sources under the hood. See, e g, VOLKSWAGEN NEW BEETLE 1999

Safety Review #762540 (May 28, 2002), MIN/car-and-safety com/volkswagen-new-beetle-

salety/volkswagen-new-beetle-2000 htm (total loss by fire from under the hood "seems to be

happening to other Beetles as well") These fires could well have been caused by the defect in

the fuse box alternator cable assembly VOLKSWAGEN NEW BEETLE 1999 Safety Review

045454 (May 16, 2001), supra See also VOLKSWAGEN NEW BEETLE 1999 Safety

Review #8023221 (Feb 12, 2002)

THE DESIGN OF THE BATTERY CABLE ASSEMBLY COULDPOSSIBLY START A FIRE UNDER THE HOOD THE BATTERYCABLE WAS SITUATED ON TOP OF THE BATTERY ALONGWITH THE FUSE BOX THIS RESULTED IN THE CABLE BEING"EATEN" THROUGH AND DRAINED THE BATTERY

http //car-and-safety com/volkswagen-new-beetle-safetv/volkswaeen-new-beetle-1999 htm

16. Volkswagen's failure to address the defect in its fuse box/alternator cable

assembly continues to this day Retailers' advertisements for replacement fuse boxes on the

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'Case 6:12-cv-01257-RBD-KRS Document 2 Filed 08/15/12 of 16 PagelD 26

Internet clearly demonstrate the longstanding problem that Volkswagen refuses to address. See,

e g, VolksToy advertisement, July 25, 2011, for replacement fuse boxes

This is an electrical part that commonly goes bad on VW's They burn

out at the fuse terminals Fuse panel sits on top of the battery andhouses bus fuses and push in fuses for various systems including theABS, fans, charging system and lighting system

yolksToy Advertisement, http //volkstovmotorsports com/99-05-VW-Jetta-Golf-Beetle-Fuse-

Panel-Box-Top-of-Batt-P382568 aspx

17 Volkswagen has failed to disclose the existence of the fuse box/alternator cable

assembly defect to consumers or to inform them of the safety issues presented, and it has failed to

correct thc defects or issue a recall

CLASS REPRESENTATION ALLEGATIONS

18 Plaintiffs bring this action on their own behalf and on behalf of all other persons

similarly situated, pursuant to Florida Rule of Civil Procedure 1 220 (Class Actions) Pursuant to

Rule 1 220(b)(3), the Class consists of all persons who own or lease Vehicles containing the

aforementioned defect and have expended unreimbursed money to repair the defect or who have the

defective assemblies where the fuse box/alternator cable has not yet melted or burned

19 The Class which Plaintiff seeks to represent is defined as

All residents of the State of Florida who purchased and/or leased the

following Volkswagen vehicles for personal, family or household usc and whotherefore have vehicles with the defective fuse box/alternator cable assemblies.

(a) thc 2003-2005 New Beetle Convertible, or (b) the 1999-2005 New Beetle (the"Vehicles") Excluded from this Class arc any person, firm, trust, corporation, or

other entity related to or affiliated with Defendant, any person, firm, trust,

corporation, or other entity who purchased a Vehicle, for resale, from Defendant,or any entity who has an action for damages for personal injury or death or

property damage against Defendants

_9_

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NUMEROSITY

20 The members of the Class are so numerous that joinder of all members is

impracticable The Class is made up of thousands of members The precise number of Class

members can only be ascertained through discovery, which includes Defendant's sales, service.

maintenance and complaint records The disposition of their claims through a class action will

benefit both the parties and this Court.

COMMON QUESTIONS OF LAW AND FACT

21 There is a well-defined community of interest in the questions of law and fact

affecting the members of the Class

Pursuant to Rule 1.220(b)(3), the questions of law and fact common to the Class

predominate over questions which may affect individual members, and include the following

a whether the fuse box/alternator cable assemblies by Defendant in the

Vehicles contained design defects that caused the fuse box and cables to melt or burn,

whether all or an identifiable portion of the Vehicles possess the design or

material defect alleged,

whether the Defendant violated Florida's Deceptive and Unfair Trade

Practices Act, Fla Stat 501 201 et seq,

whether members of the Class are entitled to be notified and warned about

the defect and are entitled to the entry of final and injunctive relief compelling Defendant to issue

a inotification and warning to all class members concerning such a defect,

whether Class members are entitled to actual damages and if so, the

appropriate amount thereof,

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whether Defendant deliberately failed to disclose material facts to

Plaintiffs and the Class members

whether Defendant gave an express warranty which was limited by time

despite Defendant's knowledge that the defect may become apparent after the warranty period

liad expired,

whether the limits of the Basic Warranty are unconscionable and therefore

unenforceable

whether the fuse box/alternator assembly is inherently defective and

should be replaced by Defendant at no cost to the Class Member, even where the assembly has

not burned or melted, because of the safety hazards presented.

TYPICALITY

23 The claims and defenses of the Fickeses as the representative Plaintiffs are typical of

the claims and defenses of the Class because Plaintiffs and the Class members all owned Vehicles

with defective fuse box/alternator cable assemblies which were designed, manufactured and sold by

Defendant Plaintiffs, like all class members, purchased their Vehicle without having received any

warning or notification from the Defendant of the defect Plaintiffs also qualify as typical of each

subclass

ADEQUACY OF REPRESENTATION

24 The Fickes, as the representative Plaintiffs, will fairly and adequately assert and

protect the interests of the Class as

a Plaintiffs have hired attorneys who are experienced in prosecuting class

action claims and will adequately represent the Interests of the Class, and

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Plaintiffs have no conflict of interest that will interfere with the

maintenance of this class action.

PREDOMINANCE

25 Questions common to the Class predominate over those which only affect individual

owners This case involves two specific models of cars The defective system parts are

interchangeable from one model and year to the next The systems are defective regardless of who

was driving the Vehicles or how they were being driven. Liability will primarily be predicated upon

thc jury's evaluation of the design and/or material used for the defective assemblies and Defendant's

awareness of the problem and its effort to resolve it

SUPERIORITY

26 A class action provides a fair and efficient method for the adjudication of

controversy for the following reasons

a. The common questions of law and fact set forth above predominate over

any questions affecting only individual Class members,

The Class is so numerous as to make joinder impracticable The Class,

however, is not so numerous as to create manageability problems There

are no unusual legal or factual issues which would create manageability

problems;

Prosecution of a separate action by individual members of the Class would

create a risk of inconsistent and varying adjudications against Defendant

when confronted with incompatible standards of conduct,

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The claims of the individual Class members are small in relation to the

expenses of litigation, making a class action the only procedure in which

Class members can, as a practical matter, recover

A class action would be superior to and more efficient than adjudicating

thousands of individual lawsuits

FIRST CAUSE OF ACTION(Deceptive and Unfair Trade Practices)(Violation of Fla. Stat. 501.201 et seq.)

27 Plaintiffs hereby incorporate by reference the allegations contained in all preceding

paragraphs of this Complaint as though set forth fully herein

28 Plaintiffs assert this cause of action on behalf of themselves and the Class.

29 Volkswagen's practices, acts, policies and course ofconduct, including its omissions,

as described above, were intended to induce, and did induce, Plaintiff and the Class members to

purchase the above-mentioned Vehicles with defective fuse box/alternator cable assemblies

31 Volkswagen's practices, acts, policies and course of conduct violated Florida's

Deceptive and Unfair Trade Practices Act, Fla. Stat 501 201 et seq, in that

a Volkswagen failed to give adequate warnings and notices regarding the use,

defects and problems with the Vehicles' fuse box/alternator cable assemblies,

to customers and consumers who purchased said Vehicles, whether original

or subsequent purchasers, despite the fact that Volkswagen possessed prior

knowledge of the inherent defects to the assemblies,

Volkswagen failed to disclose to Plaintiffs and the Class members, either

through warnings or recall notices, and/or actively concealed fact from them

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the fact that the Vehicles' fuse box/alternator cable assemblies were

defective, despite the fact that it learned of such defects at least by the

beginning of 2001 and probably before, and

c. Volkswagen forced Plaintiffs and the Class members to expend sums of

money at its dealerships to repair and/or replace defective assemblies on the

Vehicles, despite the fact Defendant had prior knowledge of the defects at the

time of purchase

31 The aforementioned conduct is and was deceptive, false, fraudulent and constitutes an

unconscionable, unfair, and deceptive act or practice in that Volkswagen has, by the use of knowing

intentional material omissions concealed the true defective nature of the fuse box/alternator cable

assemblies

32 Volkswagen has knowingly and intentionally concealed material facts and

breached its duty not to do so

33 Members of the public were deceived by Delendant's failure to disclose

34. As a direct and proximate result of these unconscionable, unfair, and deceptive acts or

practices, Plaintiffs and the Class members have been damaged as alleged herein, and are entitled to

recover actual damages to the extent permitted by law, including class action rules, in an amount to

be proven at trial

35 In addition, Plaintiffs seek reasonable attorneys fees

PRAYER FOR RELIEF

WHEREFORE, Plaintiffs, individually and on behalf of all others similarly situated, pray

for a judgment against Defendant as follows.

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a For an order certifying the Class pursuant to Florida Rule of Civil Procedure

1 220(b)(3), appointing Plaintiffs as representatives of the Class and appointing

the law firms representing Plaintiff as counsel for the Class,

For compensatory damages sustained by Plaintiff and the Class,

c. For compensatory damages and/or restitution of all funds acquired by Defendant

from Plaintiffs and the general public as a result of Defendant's unlawful, unfair,

fraudulent, deceptive and unconscionable practices described hereinabove in the

Deceptive and Unfair Trade Practices Act claim;

d. For payment of costs of suit herein incurred,

For both pre-and post-judgment interest on any amounts awarded,

For payment of reasonable attorneys' fees and expert fees, and

For such other and further relief as the Court may deem proper

DEMAND FOR JURY TRIAL

Plaintiffs hereby demand a trial by jury on all claims so triable.

Dated. Junc1, 2012

By Cli1M.a.J. ANDREW MEYERFlorida Bar No 0056766TAM RA GIVENSFlorida Bar No 657638RACHEL SOFFINFlorida Bar No 0018054MORGAN & MORGAN, P A201 North Franklin Street, 7`h Floor

Tampa, Florida 33602

Telephone (813) 223-5505Facsimile (813) 223-5402Email ameyer@forthepeople corn

tgivens@forthepeople corn

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\\19WOrsoffin@forthepeople corn

SCOTT WM WEINSTEINFlorida Bar No 563080MORGAN & MORGAN, P A

12800 University Drive, Suite 600Fort Myers, FL 33907-5337

Telephone (239) 433-6880Facsimile (239) 433-6836Email [email protected]

GARY E. MASONNICHOLAS A. MIGLIACCIOWHITFIELD BRYSON & MASON, LLP1625 Massachusetts Avenue, NW, Suite 605

Washington, DC 20036Tel (202) 429-2290Fax (202) 429-2294Email nmigliaccioRmasonlawdc corn

CHARLES A. SCHNEIDERMARTHA B. SCHNEIDERSCHNEIDER & SCHNEIDER4616 Butterworth Place, NW

Washington, DC 20016Tel (202) 364-8539Fax (202) 364-8539Email caslawdc@msn corn

GARY S. GRAIFMANMICHAEL L. BRAUNSTEIN747 Chestnut Ridge RoadChestnut Ridge, New York 10977Tel (845) 356-2570

Attorneysfor Plaintiffs and theProposed Class

pro hoc vtce admission to he sought

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